?
et
f ‘ i
toad)
Dingot undergoing scalping, The view shows two cuts being

vultancously in a vertical lathe, one across the top face and the
other on the outside diameter.

4

t
t
{
{

te ii
aD.

Fig, 9.15. The flane-etch test of dingot surface qua The application
of the torch to the spinning dingot heat-tints the surface and ere
sharp contrast between the metal and any slag inclusions that remain.



FILE; DM_reply_Allen_Nov2012.doe

strongly suggest that Weldon Spring uranium dingots, before they were cropped, the form
sent to GSI, were taller than they were wide. Mr. Allen gives the dimensions as 18 by 18
inches. This can only refer to dingots after cropping. Only uncropped dingots were
supplied by MCW (both sites) to GSI.

-4]3-



FILE: DM_reply_Allen_Nov2012.doe

Figure 1 — Average Airborne Activity while Handling Cold Metal (dpm/m*)

? ——_— —= ——

|
| 40
°

20

"| jeu
| Oy ’

Slugs Derbys Billets Dingots

The figure is arranged from left to right by the weight associated with each form of metal. No specific
pattern can be seen that would indicate one form of metal creates higher airborne activity than another.
Although it would seem intuitive that a large metal object would create more airborne activity than a
small one, as shown in Figure 2, the data indicate the opposite. In Figure 2, the average airborne activity
from handling each form of metal is normalized to the weight of the object.

MCKEEL: These data are uninterpretable because (a) the primary source of the weights
are not provided by Mr. Allen, (b) It is not clear whether or not the dingots have 100% of
the Mg-Fluoride outer crust remoyed by machining or not, (c) all of this is surrogate data
in that none of these sites (which are not known up until this point in this report) has been
stringently justified to be similar to the uranium products that MCW sent to GSI 1953-66.

Page 4


From: .
Subject: Dingots,
Date: May 12, 2009 10:11:51 PM CDT
To: Dan McKeel -
Cc: John Ramspott
@ 4 Attachments, 784 KB (Save ¥ ) (Sideshow )

Dan:

| am going to split this email into 2 sections just to make sure you get them .
These photos are in the "new' book that my Library got me.

(Amazingly they do not

Uranium production technology

By Charles D. Harrington, Archie E. Ruehle, Mallinckrodt Chemical Works. Uranium Division
Published by Van Nostrand, 1959

Original from the University of Michigan

Digitized Dec 14, 2007

579 pages

Fic, 9.10, Appearance of dingot and slag during the break-out.


FILE; DM_reply_Allen_Nov2012.doc

Site or Process Similarities

The airborne creating operations at GSI consisted only of the movement of cold uranium metal, The air
sample results presented in this white paper consists of the movement of cold uranium metal in various
forms with no or little interference from nearby operations. The various forms require different means of
moving the metal. As discussed in this paper, all forms and means of movement appear to result in similar
results and the data can therefore be considered to be from a similar process regardless of the size and
shape of metal moved at GSI. MCKEEL: This is a flawed analysis. The different sizes and
shapes gave very different results as proven by Figures 1, 2 and 3 that Mr. Allen chooses to
ignore to make his point.

Temporal Considerations

No special controls or means of handling the uranium metal have ever been reported at GSL Therefore the
airborne activity at GSI is associated with the physical characteristics of uranium metal which doesn't
change over time and no temporal considerations are relevant. However, the data was collected between
1956 and 1968 which is relatively contemporaneous to the GSI uranium work. MCKEEL: Untrue:
weighing, unload from trucks and trains, position of NDT Betatron radiography all at GSI.

Plausibility

The data used was collected while moving cold uranium metal, The analysis in this paper indicates the
results are relatively consistent regardless of size and shape of the metal or the means of movement, The
data then represent real measurements associated with conducting comparable tasks on comparable
material, Thus, the value is considered plausible,

MCKEEL: A succession of untrue statements: dimensions not authenticated by relevant
literature, “relatively consistent” is not accurate, tasks are NOT comparable tasks and
materials (no slugs or derbies at GSI), no uranium NDT radiography at any surrogate site.

Conclusion
NIOSH was uble to find 37 air samples applicable to the movement of cold uranium metal. The results
ty
were consistent across various sizes and shapes of uranium as well as several sites and years. The 95
3

percentile of the data resulted in an airborne contamination value of 104 dpm/m which is what NIOSH
intends to use at GSI. MCKEEL: The values were not consistent as Mr. Allen claims.

Page 8
References

Allen, D. 2012. “Use of Surrogate Data at GSI: Response to SC&A Review Dated July 16, 2012,"
hutp://www.cde.gov/niosh/ocas/pdfs/dps/de_gsisd_0812.pdf,

Anigstein, R. 2012. “Review of the Use of Surrogate Data for Estimating Intakes of Uranium at General
Steel Industries.” hutp://www.cde.gov/niosh/ocas/pdts/abrwh/scarpts/sca_gsisd_r0.pdf.

MCKEEL: These references are insufficient to back up Mr. Allen’s key assertions, Where
are the primary references for dimensions and weights of his four uranium forms?

Page 9. Attachment 1, part 1 follows on the next page.

-9-



FILE: DM_reply_Allen_Nov2012.doc

Figure 3 average Airborne - Activity per Square Centimeter of Surface Area (dpmn/m?/cm*)
1

|
von |
|
0.001 — i |

Shige Derbys filets Omeots

While Figure 3 shows that the airborne activity is indeed more closely related to surface area than weight,
there is still a clear trend indicating that smaller objects produce higher levels of airborne activity per unit
of surface area,

MCKEEL: Major caveats for Figures 1 and 2 also apply to Figure 3: sites not identified,
stringent comparability to GSI MCW uranium forms not justified (GSI never worked with
slugs, for example), uranium form dimensions not backed up by proper primary source
citations, no error bars, McKeel data challenges the dimensions of both slugs and dingots
provided by David Allen,

This trend can be explained by considering that airborne activity is not solely related to the amount of
oxide contamination on the surface of the metal. It is also necessary to have some force to dislodge the
contamination and suspend it into the air. When handling cold uranium metal, that force will be
associated with the mechanism used to move the metal. Movement of a four pound slug is most often
accomplished by hand, A hand can easily wrap around a one inch diameter rod and can easily cover about
half of the eight inch length. Thus, Approximately half of the surface area of the slug could be disturbed
by moving the slug. A dingot on the other hand weighs 3300 pounds and will not be moved by hand. The
use of a chitin hoist or fork truck or other means Would have to be employed. If a one inch thick chain is
wrapped around an eighteen inch diameter dingot, it would cover less than 4% of the surface area of the
dingot. While a single chain may not be employed, it is very likely that whatever means is used, a small
fraction of the surface area would be disturbed, So, it is possible that a larger fraction of the surface area
of small objects is disturbed when compared to larger objects.

MCKEEL: The accuracy and comparability to GSI-MCW uranium forms of the
measurement data from unnamed and uncharacterized surrogate sites presented as the
basis for Figures 1, 2 and 3 has been challenged. Most refereed journals insist that Figure
legends include full information to validate the information shown, including citations for
the literature. NIOSH did not conform to these widely accepted standards, so these data
and their interpretation must remain in limbo until these good science standards are met.


FILE: DM_reply_ Allen_Nov2012,uoe

Figure 2 — Average Airborne Activity Created per Pound (dpm/m*/pound)
10

;

Derbys sillets Lingots

The figure shows clearly that more airborne activity per unit mass is created from smaller objects than
from larger ones. Given that only the loose surface activity contributes to the airborne levels, it would
be more relevant to normalize the airborne activity on a surface area basis rather than a mass basis.
Figure 3 provides the results of normalizing the data in this manner. This figure Is the same as Figure 2
except that the average airborne activity is divided by the surface area in square centimeters rather than
the weight.

MCKEEL:; The same caveats apply to this Figure as to Figure 1. Another caveat that
applies equally to both figures is there is a very small “N” and no error bars indicating an
SEM or Std. Dey, are given. The legend is further unclear as being labeled “Figure 2” and
the legend stating “This figure is the same as Figure 2” when it should say “as Figure 1.”

A new factor that must be brought into the equation, that has not been previously
discussed by the work group, is the fact that at GSI, as opposed to these “new” and
“additional” surrogate sites, 24-25 Mev Betatron irradiation could volatilize activated
elements on the uranium surfaces and thereby release more airborne radioactivity.
Page 5

Figure 3 is on the following page.




PILE: DM_reply_Allen_Nov2012,doc

MCKEEL: This listing of sites and data sources by SRDB only, minus authors, report titles
and numbers, years, sites, etc. is deceptive and scientifically unacceptable. Citing only
SRDB numbers, as DCAS/NIOSH is well aware, will seriously impede and prevent the
petitioners from acquiring these references in time for the December ABRWH meeting and
give them time to prepare a proper rebuttal and defense of SEC-00105. The GSI petitioner
and co-petitioner have no access to the SRDB, and have no way to know what specific
documents SRDB numbers refer to. Dan McKeel today (Nov. 9, 2012) will submit a FOIA
request for all of these SRDB documents to the CDC Atlanta FOIA office. However, based
on hsi recent experience where a FOIA request for one such document (Harris-Kingsley
1958) where the authors and title and year were known took 2.5 months to fulfill. DOE had
to supply the document, which is supposed to arrive at McKeel’s home this morning (Nov.
9, 2012), This is another blatant example of censorship pure and simple.
+ Al . . F 5 rR 7 F
The samples were analyzed assuming they can be represented as a lognormal distribution. The resulting
distribution has a geometric mean of 21.2 dpm/m with a geometric standard deviation of 2.6. This

th ’
distribution results in a 95 percentile value of 104 dpm/m . This is the value NIOSH intends to use for
the assessment of inhalation exposure to uranium at GSL

MCKEEL; Statistically speaking, do the samples in fact have a log normal distribution?

Analysi
Below is « comparison of the proposed approach to the Board's surrogate data criteria

Hierarchy of Data

As discussed in the NIOSH white paper from August 2012, the only data available at GSI is FUSRAP
data from 1993 und the use of the surrogate data presented in this paper would represent less uncertainty
than back extrapolating the FUSRAP data over a 40 year period.

MCKEEL; None of the surrogate data produced by Mr. Allen satisfies this criteria,

SC&A also pointed out in its review that appropriate adjustments to the TBD_6000 data were not made.
NIOSH believes the intent of that statement in the surrogate data criteria is intended to apply to
adjustments necessary to make the data applicable to the site. This is not to be confused with other
parameters used (o estimate intakes from the data such as exposure time. Those parameters would be

Page 7

used even on measurements take ut the site, They are therefore, not related to surrogate data. While it is
agreed those parameters are subject to review, NIOSH disagrees that the surrogate data criteria would be
relevant in that review,

MCKEEL: This is an arcane irrelevant argument by Mr. Allen. I agree with SC&A.

Exclusivity

This criterion requires that the use of surrogate data be stringently justified. SC&A pointed out in its
review that the use was not justified in Appendix BB. NIOSH agreed in the white paper dated August
2012 and intends to include justification made here in the next revision to Appendix BB.

MCKEEL: Given that 20 of 37 samples came from complex DOE sites, this is impossible.

oe



Dragon, Karen E. (COC/NIOSHIEID)

From: DanMcKeel.

Sent: Saturday, November 10, 2012 9:16 AM

To: NIOSH Docket Office (CDC)

Ce: danmckeel’

Subject: Fwd. McKeel Comment on Allen Nav 2012 GSI Discussion Paper
Attachments: McKee! Comment on Allen Nov 2012 GSI Discussion Paper

To the NIOSH Docket Office

Attachment: <McKeel_Comment_AllenNov2012.pdf> 1.1 MB
Please accept the attached PDF file as my comment on David Allen's DCAS/NIOSH latest Discussion paper on the
General Stee! Industries (GS!) site. The Allen Paper was prepared for the TBD-6000 work group at its scheduled Nov. 28,
2012 next meeting. The Allen paper analyzes additional surrogate data sources to be used in a future revision to
Appendix BB to account for uranium intakes at GSI. | wasn't sure whether or not Ted Katz, DFO, forwarded your office a
copy of the attachment. Thank you.

~Dan McKeel 11/10/12
In a message dated 11/9/12 12:40:44 PM, writes
Paul Ziemer, Chair, and members of the TBD-6000 work group
Ted Katz, ABRWH DFO
Members of the ABRWH full Board
NIOSH Docket 140 (GSI) Office
November 9, 2012
Attachment: <McKeel_Comment_AllenNov2012.pdf> 1.1MB

Dear Dr. Ziemer,

(have attached as a PDF file my comment related to the latest David Allen and DCAS/NIOSH Discussion paper that was
posted on the DCAS website on 11/8/12

Ted Katz, please distribute this Discussion comment paper to the full Board membership.

NIOSH Docket 140 Office, please consider posting this message and the attached PDF file ta the DCAS website as a
discussion paper for the Nov. 8, 2012, TBD-6000 work group meeting,

Thank you —Dan McKeel 11/9/12

Daniel W. McKeel, Jr., MD
GSI SEGC-105 co-petitioner

Daniel W. McKeel, Jr, MD


FILE: DM_reply_Allen_Nov2012.doc

34390 2 50 11 Fernald derby 8/19/1963
34390 | 2 34 11) Fernald derby | 3/19/1963
34390 |3 60 11) Fernald derby 8/19/1963
34390 3 74 «ay Fernald derby 8/19/1963
34390 | 3 47 Fernald derby 8/19/1963
34390 |3 88 1 Fernald derby 8/19/1963
34390 |3 110 «, Fernald derby 8/19/1963
34390 | 3 60 11) Fernald derby | 8/19/1963
12363 | 78 24 Weldon Springs dingots | 11/14/1960
12363 | 78 21 Weldon Springs dingots | 11/14/1960
12363 | 22 56.24 aya) | Weldon Springs dingots | 7/26/1961
12363 | 22 66.6 (442) | Weldon Springs dingots | 7/26/1961
12363 | 22 46.62 «xyz, | Weldon Springs dingots | 7/26/1961
14956 | 4 25 Weldon Springs slugs 3/30/1960
14956 | 4 25 Weldon Springs slugs 3/30/1960
14956 [4 25 Weldon Springs slugs 3/30/1960
17254 6 11.8 Weldon Springs dingots | 12/10/1956
17254 1/6 nd Weldon Springs dingots | 12/10/1956
17254 | 6 23.7 Weldon Springs dingots | 12/10/1956



FILE: DM_reply_Allen_Nov2012.doc

Attachment 1 — Airborne Activity Samples

SRDB# | Pg Activity | Site type Date
(dpm/m’)
10634 | 11 9 Leblond billets | 8/22/1961
10634 | 11 nd Leblond billets 8/22/1961
10634 | 11 nd Leblond billets | 8/22/1961
10634 | 11 15 Leblond billets 8/22/1961
10634 | 11 nd Leblond billets | 8/22/1961
10634 11 nd Leblond billets 8/22/1961
43252 | 2 24 Chambersburg slugs 3/21/1957
43252 | 2 5 Chambersburg slugs 3/21/1957
43252 | 2 28 Chambersburg slugs 3/21/1957
93533 | 129 53 Tocco slugs 2/16/1968
98533 | 129 22 Tocco slugs 2/16/1968
98533 | 124 5 Tocco slugs 6/6/1968
98533 | 124 37 Tocco slugs 6/6/1968
98533 | 124 5 Tocco slugs 6/6/1968
98533 | 124 24 Tocco slugs 6/6/1968
98533 124 nd Tocco slugs 6/6/1968
98533 | 124 19 Tocco slugs 6/6/1968
| ee: |2 45 ay Fernald derby | 8/19/1963 |

-10-


FILE: DM_reply_Allen_Nov2012.doe

The entire rationale given in the preceding paragraph is also suspect. Of course it is true
that “airborne activity is not solely related to the amount of oxide contamination on the surface
of the metal." Uranium ingots and dingots, and according to Mr. Allen derbies as well, must
haye the outer magnesium-fluoride and oxide crust removed. This coating was unevenly
thick over the metal product surfaces, and data for the thickness of the crust of uranium
derbies and dingots at the surrogate sites and at GSI are not known. For Betatron slices,
which MCW sent to GSI apparently, the cut surfaces were presumably exposed bare
uranium metal with some oxide accumulation, whereas the sides of the slices (~4 inch thick
slabs cut from ingots and dingots) was coated with variable amounts of “bomb” crust,
Extra handling of ALL MCW uranium sent to GSI was necessary for unloading from
trucks and rail cars, weighing, and positioning associated with Betatron x-ray NDT
radiography. These technical factors cannot and should not be dismissed as “trivial” or
“negligible” or “insignificant” unless and until exacting measurement data are available
that can be stringently justified as being comparable to the conditions that existed during
Betatron X-ray radiography handling of MCW uranium forms at GSI 1953-1966.

Page 6

While this may explain why more airborne contamination per unit surtace area is created from small
objects, it is also true that large objects contain more surface area overall, Given these (wo competing
concepts, it is not obvious which form of metal will create more airborne contamination. Based on Figure
|, it appears as though the size of object being handled is not related to the amount of airborne
contamination created, From Figures 2 and 3, it also appears that the airborne contamination created from
the movement of cold uranium metal is independent of weight and surface area, Based on the data
reviewed, however, the levels of airborne activity are relatively low and are can be represented by a fairly
consistent quantity regardless of the form of the metal. Therefore, to establish the range of exposures
associated with the movement of cold uranium metal, all the data in Table | were combined into a single
distribution of airborne activity.

MCKEEL:; Yes, it is obvious that slugs create the highest airborne uranium values because
they have the largest surface area per unit volume. This is the basic principle that Mr.
Allen, a health physicist, appears to have missed. There is no justification for combining
these disparate uranium form samples to overcome a basic lack of relevant Surrogate data.
Slugs were not used at GSI, and billets are an undefined size, shape and weight. Moreover,
the postulated GSI billets from MCW have not been adequately characterized as to shape,

size, dimensions, or composition, or amount of radioactivity associated with their surfaces.

Uranium derbies were not handled at GSI. Mr. Allen’s surrogate intake data is weak and

poorly characterized and is not similar to GSI-MCW uranium products, and there is no
escaping or hiding this fact.

NIOSH and DCAS need to admit they lack sufficient air sampling (all three types), urine
uranium bioassays, and film badge monitoring data at GSI to bound uranium intakes and
activated steel casting radioactivity at GSI during either the operational AEC contract
period of 1953-66 or during the 1967 to 1993 residual contamination period.

Attachment | contains the results for the samples utilized in this report, The attachment includes the Site
Research Database document number and page number where the sample was located, It also includes the
site from which the samples were collected as well as the type of metal and the date the sample was
collected, A few of the values are listed as “nd” which represents a “none detectable” sample.

Ace


FILE: DM_reply_Allen_Nov2012.doc

cleaned off by mechanical means, The operations found associated with derbies include breaking the
derby out of the pot, cleaning the magnesium fluoride from the derby and removing the derby from the
table. The airborne contamination results in these steps may be interfered with by the mechanical removal
of the derby from the pot and the mechanical removal of the magnesium fluoride from the derby.

However, most of the dust created in those operations is from magnesium fluoride and though it is
contaminated with uranium, the concentration is low and so the interference should be small.
contaminated with uranium, the concentration 1s low and so the interference should be small

MCKEEL emphasis added. The above description conforms to a one step Mallinckrodt
patented dingot process. To produce ingots, several derbies were first produced and these
were heat remelted and cast into uranium ingots in a heated “bomb.”

A billet is a generic metallurgical term used to describe a semi_finished piece of metal. In uranium fuel
fabrication, it is a piece of uranium metal that was originally cast into an ingot and rolled into a smaller
dimension using a blooming mill. The billet would later be further rolled to a finished product using a
rolling mill. The billets associated with the data found for this Teport were approximately 7 inches in
diameter and 20 inches long. This would result in a billet weighing approximately 525 pounds,
MCKEEL. The exact references need to be cited here: author, title, site, date published,
agency report number, SRDB no., etc. The key question is not the dimensions of the billet
in some other site, but rather the uranium billet dimensions that MCW Uranium Division
supplied to GSI 1953-1966 for Betatron radiographic nondestructive testing (NDT) that
induced both activation and photofission in the irradiated uranium, Those are the relevant
comparison billet specifications that must be known and reported by NIOSH, if they assert
the claim the “new” “additional” surrogate site/s are stringently justified to be comparable
to MCW/GSL.

Page 3

A dingot (direct ingot) is a term used at Mallinckrodt to describe an ingot made directly from the metal
reduction process. The alternative procedure was to remelt several derbies and cast them into ingots. The
dingot is approximately 18 inches in diameter and 18 inches long weighing approximately 3300 pounds.
MCKEEL: Uncropped MCW dingots were not square as Mr. Allen states. As I show later
Weldon Spring dingots came in several sizes and shapes. Mr. Allen needs to provide a solid
literature citation to back up his recital of MCW uranium dingot dimensions. We agree the
weight of an idealized MCW dingot was approximately 3300 pounds.

is of S:
Air samples were found related to handling cold uranium metal in each of the four forms described above.

The sample results, along with the form associated with the sample, are provided in Attachment
1. Figure | graphically depicts the average airborne value associated with handling each form of uranium,


From: '. ”
Subject: Dingots/Ingots at GSI, "WHY"?
Date: April 10. 2009 2:44:57 PM CDT
To: r : :
@ 4 Attachments, 822 KB (Save » sidesnow }

The initial concept of the dingot process was to eliminate the vacuum
casting by collecting the metal from a bomb reduction in a properly
shaped cavity to permit direct rolling of the scalped regulus. The hot
magnesium fluoride slag produced in the reaction would keep the
upper portion of the metal molten longer than the bottom, and thus
provide for directional solidification of the metal. Chemical cnalysis

and Seige ee of early dingots confirmed the expectation
that the inne’ re of the dingot, un eSplBH ots Surtoce set

was sound metal of exceptional purity. Difficulty was experie ;
however, in attempting to roll the scalped reguli in the existing rolling


Fuel Tests:

Uranium, like most metals, shrinks on
solidifying and blowholes and pipes are
formed in the ingots. The amount of
metal to be removed by cropping in order
to produce sound material for rolling is
determined by the use of high-energy
X-rays. This test has supplemented other
work in aiding the development of im-
proved casting techniques. Uranium al-
loys may be cast in rounds or flats so that
very little if any machining is required
for use. Such bars may be tested by ul-
trasonic techniques for soundness.


FILE; DM_reply_Allen_Nov2012.doe

Cold uranium metal, as used in this while paper, refers to uranium that has not been physically heated,

Page 2

search was to find samples related to handling cold uranium metal and elevated temperatures can have a
great effect on the production of oxides on the surface. An example of this can be seen at the Weldon
Springs Site. In an outgassing procedure, 60 slugs were loaded into wire baskets and 8 baskets were
loaded into a “boat” which was placed into a furnace. When the slugs were placed in the basket, the

airborne level was 25 dpm/m . When the slugs came out of the furnace, they had to be handled to read the
numbers stamped in the slug, The measured airborne level from this handling operation was 1530

dpm/m .

MCKEEL: The correct site name is Weldon Spring (singular). GSI did not handle uranium
slugs. They did handle uranium dingots from the Weldon Spring site 1957-66. Uranium
dingot data are the relevant data that are needed to assess and bound intakes at GSI with
sufficient accuracy.

As a result of the expanded data search, a few additional samples were, however, located that have litle

or no influence from nearby operations, The samples include data collected at several facilities and cover
the years 1956 through 1968. The data also cover operations involving four forms of uranium metal:

slugs, derbies, billets and dingots.

MCKEEL: All of the “additional sample” sites listed later in this white paper are not new.
For example, LeBlond was a site introduced by NIOSH at the August 2012 TBD-6000 work
group meeting.

Forms of Uranium

Slugs were typically 8 inches long and approximately | inch diameter weighing approximately 4
pounds. They were intended to be used as fuel in plutonium production reactors. Operations associated
with the selected samples primarily involved moving slugs into or out of a container.

MCKEEL: At the August 28 work group meeting SC&A introduced data that slugs were
only 1/2 x 3/4 inch in size. Mr. Allen’s figures are considerably different. What is his
primary reference source? Is it different from Dr. Anigstein’s and the SC&A reference
source for slug dimensions? Despite Ms. Munn’s comment that everything is known about
uranium metal, there seems to be considerable disagreement about fundamental facts
such as the size of uranium slugs.

Derbies are approximately 12 inches in diameter and 4 inches high weighing approximately 300 pounds
MCKEEL; What is the primary reference source for these measurement values?

They are created by a thermite process used to reduce uranium tetrafluoride to uranium metal
MCKEEL. The details of the “thermite process” needs to be clarified and explained, What
are the specifics of this process, and what is Mr. Allen’s primary reference source for the
thermite process he is referring to?

Once produced, the derby has to be “broken out” of a reduction pot and the excess magnesium fluoride

<2


FILE: DM_reply_Allen_Nov2012.doe

Daniel W. McKeel, Jr., GSI SEC-105 Co-petitioner
Comment on Dayid Allen DCAS White Paper
“Evaluation of Additional Air Sample Data
Applicable to GSI” Received Nov, 6, 2012

Page 1

Background

On July 16, 2012, SC&A submitted a review of NIOSH’ use of surrogate data at GSI to the TBD_6000
work group (Anigstein 2012). NOSH responded to that review in a white paper dated August 2012 (Allen
2012). Both papers were discussed during a work group meeting held on August 28. 2012. Asa result of
this discussion, the work group asked NIOSH to locate and review additional air sampling data associated
with the movement of cold uranium metal. This paper presents the data collected in response to that
request; and provides an analysis of the applicability of the data to bounding the inhalation of uranium at
GSI.

MCKEEL: The background should include the facts that on August 28 SC&A reported the
NIOSH TBD-6000 intake model for GSI was invalid and failed to meet 4 of 5 Board
surrogate data criteria, The work group did not accept the “new” surrogate data from
LeBlond and two other AWE sites two of which handled uranium slugs and the other
uranium billets. None handled dingots or ingots of the type sent by MCW Destrehan Street
and Weldon Spring site to GSI. None of the three “new” surrogate data sites were
stringently justified as being similar in scope of operations and source terms to GSI. The
intake data offered were very scant and did not include breathing zone, general air and
process sampling as recommended by HASL. There is no uranium urine bioassay data for
any worker at GSI. Only 3% of the work force in a single job category, radiography, were
ever badged.

Data Collected

Pursuant to the working group’s request, NOISH broadened its search for data related to the handling of
cold uranium metal. Difficulties associated with finding this type of data are pointed out in the NIOSH
white paper issued in August 2012. In summary, the difficulties include:

a) The operation is not normally a source of high airborne activity so few samples were taken; and,
b) When the metal is moved, it is normally for the purpose of performing some mechanical

operation. These mechanical operations often cause high airborne activity in the vicinity.
thereby positively skewing the results.

In searching the NIOSH site research database, some air samples were found in which it was difficult to
determine if they were representative of the movement of cold uranium metal. An example is the general
area air samples found for an ingot storage area at Fernald, The sample dese ptions contained no
indication of what, if any, work was occurring in the area, therefore, the samples were not used. Other
samples that were located also may have been interfered with by nearby airborne activity generating
operations. Finally, if the metal was heated, samples associated with additional steps soon after were
assumed to be associated with heated metal and were not used. The intent of our data



FILE: DM_reply_Allen_Nov20]2,doc

MCKEEL COMMENT ON ATTACHMENT 1,

1. Part of Attachment 1, Chambersburg and LeBlond samples were in the August 2012
Allen white paper and thus are not “additional” sites.

2. [have never heard of a Tocco site and thus have no way to know how similar it may be
to GSI.

3. This Attachment is further deliberately vague in not giving the exact number of samples
that contributed the radioactivity values stated in column 3. Some values are averages.

4. Page numbers from documents identified only by SRDB numbers are meaningless.

5. These values are NOT REPRESENTATIVE of uranium forms used at GSI and do not
include ingots and Betatron slices of ingots. GSI did not handle or do NDT radiography on
uranium slugs or derbies per se.

6. Of the cells in column [5], 9 were derby, 6 were billets, 14 were slugs, and 8 were dingots
from Weldon Springs (sic). Total n=37, OF those, only billets and dingots, total n=14, were
possibly used at GSI. Thus 23 of 37 samples in Attachment 1, or 62.1% of total samples
cited by Mr. Allen, are irrelevant to work done at GSI under contract with the AEC 1953-
1966.

7. Twenty (20) of 37 (54%) total samples were from DOE sites (Weldon Spring, Fernald)

that differed markedly in scale and scope of activities from work done under contract for
the SEC at the General Steel Industries (GSI) AWE site in Granite City, Illinois, Such large
scale DOE site cannot reasonably or plausibly be justified stringently as being comparable
to GST in any way. To do so would be scientifically absurd and indefensible.

8. Petitioner records show that uranium dingot production did not develop at Weldon
Spring site (WSS) until 1957. The 12/10/12 dates on the last three Weldon Spring dingot
samples listed in the Attachment 1 table are therefore suspect, underlining the need for a
specific supporting reference.

9. As I show again on the last pages of this report that follow, dingots at Weldon Spring
came in several different shapes and sizes, The photos suggest that uncropped Weldon
Spring dingots are taller than wide before cropping. Mr. Allen needs to characterize the
sizes and shapes of his uranium samples, and the Attachment 1 dingot and billet air
samples data, in much greater detail in order to make Figures 1, 2 and 3 more credible as
being similar to those used at GSI. The slug and derby data is not credible because those
uranium forms were not handled at GSI. And Betatron slices, that were used at GSI, toa
large extent claimed in some SC&A reviews of GSI, are not represented in the Allen
surrogate uranium samples.

McKeel Summary Comment: The sampling cited in ATTACHMENT | cannot possibly be
interpreted without having the related primary technical documents. The attached photos

4122


mill because of their short length. Reguli of greater length would
result in greater scalping losses. The best solution to this problem
seemed to be the adoption of a primary hot forming step prior to final
fabrication by rolling or extrusion. This would provide an additional
advantage in that it would permit the design of bomb shapes producing
optimum metal yields.

somponents. In addition, the develop-
ment of various types of power reactors
zequired fuel clements of many different
sypes, and special nondestructive tests
sere required. Consequently several of
he Atomic Energy Commission contrac-
sors and subcontractors began rather
extensive programs in nondestructive
H vesting. The various contractors included
she fuel manufaclurers, Mallinckrodt
Chemical Works, and the National Lead
fo. at Fernald, and the various labora-
sories interested in fucl element manu-
facture including Knolls Atomic Power
Laboratory, Hanford Atomic Products
Operation, Savannah River Laboratory,
Westinghouse Atomic Power Division,
4:omics International (NAA), California
Research and Development Co., Argonne
National Laboratory, Oak Ridge Na-
-ional Laboratory, Los Alamos Scientific
Laboratory, Battelle Memorial Inst.,
Sylvania Electric Products, Inc. and the
New York Operations Office. An informal